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Home My WebLink About07-6064RICHARD M. BARONE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0-7- (00(0 U 01') JOANN M. GULA, CIVIL ACTION -LAW Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. The Plaintiff is Richard M. Barone, currently residing at 126 Old Schoolhouse Lane, Mechanicsburg, Pennsylvania 17055. 2. The Defendant is Joann M. Gula, currently residing at 332 Equus Drive, Camp Hill, Pennsylvania 17011. 3. Plaintiff seeks primary custody of the following child: NAME PRESENT RESIDENCE Ben Joseph Barone 332 Equus Drive Camp Hill, PA 17011 and 126 Old Schoolhouse Lane Mechanicsburg, PA 17055 Based on a shared custody schedule per agreement of the parties: 4. The child was not born out of wedlock. D.O.B. 5/18/2004 5. The child is presently in the shared custody of both mother and father who reside as set forth in paragraphs 1 and 2 hereof. 6. During the past five years, the child has resided with the following persons and at the following addresses: NAME Richard M. Barone Joann M. Gula RESIDENCE 332 Equus Drive Camp Hill, PA 17011 10/5/2007 Joann M. Gula 332 Equus Drive 10/5/2007 Camp Hill, PA 17011 to present and Richard M. Barone 126 Old Schoolhouse Lane 10/5/2007 Mechanicsburg, PA 17055 to present 7. The mother of the child is Joann M. Gula, currently residing at 332 Equus Drive, Camp Hill, Pennsylvania 17011. She is married. 8. The father of the child is Richard M. Barone, currently residing at 126 Old Schoolhouse Lane, Mechanicsburg, Pennsylvania 17055. He is married. 9. The relationship of Plaintiff to the child is that of father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Ben Joseph Barone Son (shared custody with the Defendant) 10. The relationship of Defendant to the child is that of mother. The Defendant currently resides with the following persons: NAME Ben Joseph Barone, age 3 Riley Gula, age 12 Emily Gula, age 13 Zachary Gula, age 17 RELATIONSHIP Son (shared custody with the Plaintiff) Son from prior marriage (shared custody on an alternating week schedule) Daughter from prior marriage (shared custody on an alternating week schedule) Son from prior marriage (primary custody) 11. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 12. The best interest and permanent welfare of the child will be served by granting the relief requested because the Plaintiff is self-employed and well able to maintain primary custody of his child since he is available to the child at any time. 13. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, the Plaintiff, Richard M. Barone, requests the court to grant him primary custody of the minor child, Ben Joseph Barone. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: (?' I a (1 By: t J. onn ly, Jr. rn I.D. 15615 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff VERIFICATION I, Richard M. Barone, verify that the statements made in this Pleading are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: M-Iak-0 Richard M. Barone RICHARD M. BARONE, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. JOANN M. GULA, CIVIL ACTION -LAW Defendant IN CUSTODY CERTIFICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the Plaintiff, Richard M. Barone, hereby certify that I have served a copy of the foregoing Complaint for Custody on the following on the date and in the manner indicated below: VIA U.S. MAIL, FIRST CLASS, PRE-PAID John W. Purcell, Jr., Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102-2392 JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: ? a -- 1 D" 01-\ By: J Ne. lly, Jr. A #15615 JQ P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff N S `{ r.f W RICHARD M. BARONE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOANN M. GULA DEFENDANT • 2007-6064 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Tuesday, October 23, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, November 14, 2007 at 9:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ Dawn S. Sunda Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 3c PrVW (2 `? ? ? ? "mil Low-o/ SO .P, Wd ?Z 130 LOOZ ]Hi -10 JAN 0 7 2008 RICHARD M. BARONE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2007-6064 CIVIL ACTION LAW JOANN M. GULA Defendant IN CUSTODY ORDER AND NOW, this 2nd day of January, 2008 , the conciliator, having received no request from counsel for either party to reschedule the custody conciliation conference originally set for November 14, 2007, hereby relinquishes jurisdiction. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator ? ? ?? P- x ?' .9 , ??? f ?? ? ? 1'" d ???? OFn4%&mwir John J. Connelly, Jr., Esquire Attorney I.D. No. 15615 James Smith Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorneys for Plaintiff/Petitioner 2010 FED -3 RM 2=1A RICHARD M. BARONE, Plaintiff/Petitioner V. JOANN M. GULA, Defendant/Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-6064 : CIVIL ACTION -LAW : IN CUSTODY PETITION FOR CUSTODY ORDER AND NOW, comes the Plaintiff/Petitioner, Richard M. Barone, by and through his counsel, John J. Connelly, Jr., Esquire of James, Smith, Dietterick & Connelly, LLP and files this Petition for Custody Order as follows: 1. The Petitioner, Richard M. Barone, is the Plaintiff in the above-captioned action, currently resides at 126 Old Schoolhouse Lane, Mechanicsburg, Pennsylvania 17055. 2. The Respondent, Joann M. Gula, is the Defendant in the above-captioned action, currently resides at 332 Equus Drive, Camp Hill, Pennsylvania 17011. 3. The parties are the parents of one minor child, namely, Ben Joseph Barone, date of birth May 18, 2004. 4. In correspondence dated October 23, 2007 and November 7, 2007, the parties confirmed their existing custodial schedule pursuant to the attachment to the October 23, 2007 VERIFICATION I, Richard A Barone, verify that the statements made in the foregoing Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: I b EXHIBIT "A" JAMES SMITH DIET=CK & CONNELLY LLP John J. Connelly, Jr. 6 -6sdexom FAX 717.533.7771 P.O. BOX 650 HERSHEY, PA 17033 November 7, 2007 Couner Address 132 SIPE AVENUE VIA FACSIMILE 234-0409 TEL „' 533 328( AND U.S. MAIL WWVJ.JSDC.COFdi John W. Purcell, Jr., Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102-2392 Re: Richard M. Barone / Joann M. Gula Dear John: GARY L. JAMES MAX J. SMITH, JR. I confirmed with my client in my meeting yesterday that the parties are operating JOHN J. CONNELLY, JR. under the attached schedule that I forwarded in my October 23, 2007 correspondence. SCOTT A. DIETTERICK JAMES F. SPADE MATTHEW CHABAL, Ill SUSAN M. KADEL I am also enclosing the documents from the PFA and requesting that your client JARAD W. HANDELMAN consider withdrawing the Petition since the Temporary Order was denied and there DONNA M. MULLIN NEIL W. YAHN should be no restriction on contact with Ben given our shared custody agreement. COURTNEY K. POWELL KIMBERLY A. BONNER JEFFREY M. MCCORMICK KAREN N. CONNELLY As to the PFA itself, since I believe it was designed to remove him from the home JOHN M. HYAMS when at that point in time he was not leaving until the custody situation was resolved, the OF COUNSEL: issue is now academic. Wasting time and resources to attend the hearing of this sort GREGORY K. RICHARDS BERNARD A. RYAN, JR. takes us backward not forward and is of little purpose. We should have Dawn Sunday enter an Order based on the stipulated schedule, include language regarding Dr. Shienvold's evaluation and the parties equally sharing the cost, and indicate that either party has a right of reasonable telephone access to the child when in the other party's custody. Please let me know your thoughts as soon as possible. Very truly yours, o J. Connelly, Jr. JJC/mbl Enclosure cc: Richard M. Barone JAMES SM M DL7rmCJC & CONNELLY LLP John J. Connelly. Jr. 1i61 isdc. coin FAX 717,533.7771 P.O BOX 650 HERSHEY, PA 17033 October 23, 2007 Courier Address: 131 SIPE AVENUE HUPdMELSTCIYVN. P.4 1703E VIA FACSIMILE 234-0409 1E L. i 17 533,3280 AND U.S. MAIL WWW.JSDC.COM John W. Purcell, Jr., Esquire Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102-2392 Re: Richard M. Barone / Joann M. Gula Dear John: - GARY L. JAMES Attached to this correspondence is a schedule 1 believe the parties have worked MAX J. SMITH, JR. JOHN J. CONNELLY, JR. out. This schedule began on Sunday, October 21, 2007, which is Week 1. I believe the SCOTT A. DIETTERICK JAMES F SPADE schedule satisfies both the party's needs and reflects changes each party made in the original schedule SUSAN M.CKADELL 111 JARAD W. HANDELMAN . b DONNA M. MULLIN NEIL W. YAHN Please confirm the acceptability of this schedule since my client intends to operate COURTNEY K. POWELL KIMBERLY A. BONNER within its framework as evidenced by the return of the child to mother's residence on Sunday, October 21, 2007 at 7:00 p.m. KAREN N. ?; ELLY JOHN M. HYAMs I will await your response. OF COUNSEL: GREGORY K. RICHARDS BERNARD A. RYAN, JR. Very John V. Connelly, Jr. JJC/rnbl Enclosure cc: Richard M. Barone Week 1 Sunday evening - with mother Monday day / Monday evening - with mother Tuesday day - with mother, father picks up Ben or mother drops Ben off @ 7:00pm Tuesday evening Wednesday day / Wednesday evening - with father Thursday day / Thursday evening - with father Friday morning (9:30am) - Ben dropped off @ mothers or mother picks Ben up @ fathers Friday day / Friday evening - with mother Saturday day / Saturday evening - with mother Sunday day - with mother Sunday evening @ 7:00pm - Ben dropped off at fathers house Week 2 Sunday evening - with father Monday day / Monday evening - with father Tuesday day - with father, father drops off Ben or mother picks up Ben @ 7:00pm Tuesday evening Wednesday day / Wednesday evening - with mother Thursday day / Thursday evening - with mother Friday morning (9:30am) - Ben dropped off @ fathers or father picks Ben up @ mothers Friday day / Friday evening - with father Saturday day / Saturday evening - with father Sunday day - with father Sunday evening @ 7:00pm - Ben dropped off at mothers house CERTIFICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for RICHARD M. BARONE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-6064 JOANN M. GULA, CIVIL ACTION -LAW Defendant IN CUSTODY the Plaintiff/Petitioner, Richard M. Barone, hereby certify that I have served a copy of the foregoing Petition on the following on the date and in the manner indicated below: VIA U.S. MAIL. FIRST CLASS. PRE-PAID Timothy M. Barrouk, Esquire The McShane Firm, LLC 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: a, 9 , 10 By: Attorneys for Plaintiff P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 RICHARD M. BARONE IN THE COURT OF COMMON PLEAS OF Pt.AINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JOANN M. GULA DEFENDANT 2007-6064 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, February 08, 2010 _ upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Thursday, March 11, 2010 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunda Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORT14 BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 OF THE PPO (?NIOTARY 2019 FEB -8 PIS 4: 11 CUfit" "UNTO' P"N% 13- ;'dl?? MAR 2 2 Z01( RICHARD M. BARONE Plaintiff vs. JOANN M. GULA Defendant AND NOW, this consideration of the attached IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c? a 2007-6064 CIVIL ACTION LAW IN CUSTODY ;. r ORDER OF COURT - day of a v Z-1 Z , 2010, upon Conciliation Report, it is ordered and directed as follows: 1. The Father, Richard arone, and the Mother, Joann M. Gula, shall have shared legal custody of Ben Joseph Barone, born M 18, 2004. Major decisions concerning the Child including, but not necessarily limited to, his healt , welfare, education, religious training and upbringing shall be made jointly by the parties after discu sion and consultation with a view toward obtaining and following a harmonious policy in the Child' best interest. Neither party shall impair the other party's rights to shared legal custody of the Chill . Neither party shall attempt to alienate the affections of the Child from the other party. Each part shall notify the other of any activity or circumstance concerning the Child that could reasonably be xpected to be of concern to the other. Day to day decisions shall be the responsibility of the parent t en having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the Child at the time of the emergency shall be permitted to make any i ediate decisions necessitated thereby. However, that parent shall inform the other of the emergen y and consult with him or her as soon as possible. In accordance with 23 Pa.C.S.A. §5309, each party hall be entitled to complete and full information from any doctor, dentist, teacher, professional or uthority and to have copies of any reports or information given to either party as a parent as author zed by statute. 2. Pending further Ordeiof Court or agreement of the parties, the parties shall have physical custody of the Child in accordan e with the following bi-weekly schedule: A. Week I: Duri g Week 1, the Mother shall have custody of the Child from Sunday at 7:00 p.m. through Tuesday at 7: 0 p.m., the Father shall have custody from Tuesday at 7:00 p.m. through Friday at 9:30 a.m., and he Mother shall have custody from Friday at 9:30 a.m. through Sunday at 7:00 p.m. B. Week II: Duri g Week II, the Father shall have custody of the Child from Sunday at 7:00 p.m. through Tuesday at 7: p.m., the Mother shall have custody from Tuesday at 7:00 p.m. through Friday at 9:30 a.m., and he Father shall have custody from Friday at 9:30 a.m. through Sunday at 7:00 p.m. C. Pending the fo low-up custody conciliation conference scheduled in this Order, when the Father has to work duri g his periods of custody and the Mother is otherwise available, the Mother shall have custody of the hiId during the Father's work time. 3. The parties shall m ke arrangements to participate in a course of co-parenting counseling with a professional to be selec ed by agreement between the parties. The purpose of the counseling shall be to assist the parties in stablishing sufficient communication and cooperation to enable them to effectively co-parent their Chi d. The parties shall select the counselor and contact the counselor's office within 10 days of the cu tody conciliation conference in order to schedule the initial session. 4. The parties shall m e arrangements for the Child to participate in counseling with a professional to be selected by greement between the parties. The purpose of the counseling shall be to assess and monitor the Chil 's emotional well-being in connection with the custodial situation and to provide guidance, as approp iate, to the parties. 5. The parties shall select the counselor for the Child and contact the counselor's office within 10 days of the custody conciliation conference to schedule the initial appointment. 6. The parties shall sh#e or alternate having custody of the Child on holidays as follows: A. Christmas: from Christmas Eve at 12:00 n run from Christmas Day at 12: the Father shall have custody o Segment B. In odd numbered y the Father shall have custody dt B. In the event t: by agreement, the parties shall e In even numbered years, the Fat Thanksgiving and the Mother sl years, the Mother shall have cus Father shall have custody for M provision shall include the entire as to result in one parent having parties shall exchange another v resume the alternating schedule. C. The holiday c custody schedule. 7. Each parent shall be year for vacation upon providin schedule their vacation weeks u However, for a vacation rental i vacation shall cooperate with th following week. The Mother A through the following Saturday, agreement. The parties shall co he Christmas holiday shall be divided into Segment A, which shall run :)n through Christmas Day at 12:00 noon, and Segment B, which shall ) noon through December 26 at 12:00 noon. In even numbered years, the Child during Segment A and the Mother shall have custody during :ars, the Mother shall have custody of the Child during Segment A and ring Segment B. ie parties are unable to make arrangements for the remaining holidays lternate having custody of the Child on the major holidays as follows: her shall have custody of the Child for Easter, July Fourth and all have custody for Memorial Day and Labor Day. In odd numbered tody of the Child for Easter, July Fourth and Thanksgiving and the -mortal Day and Labor Day. The holiday periods of custody under this holiday weekend. In the event a holiday weekend falls in such a way custody of the Child for more than two consecutive weekends, the eekend either immediately before or following the holiday so as to schedule shall supersede and take precedence over the regular ititled to have custody of the Child for one uninterrupted week each at least 30 days advance notice to the other parent. The parties shall ier this provision to include their regular weekend period of custody. rich runs from Saturday through Saturday, the parent taking the other parent to schedule a makeup day in the prior or immediately 11 have custody of the Child in 2010 from June 25 in the evening with an extra day scheduled for the Father during the prior week by )erate in obtaining a passport for the Child. 8. The parties and counsel shall attend a follow-up custody conciliation conference in the office of the conciliator, Dawin S. Sunday, on Wednesday, June 2, 2010 at 8:30 a.m. for the purpose of further addressing the custodial arrangements following the co-parenting counseling required by this Order. 9. Neither party shall o or say anything which may estrange the Child from the other parent, injure the opinion of the Child as to the other parent, or hamper the free and natural development of the Child's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Child comply with thi provision. 10. This Order is conference. The parties may mutual consent, the terms of cc: `'J J. Connelly, Jr. , imothy M. Barrouk, 1?4F iSs 31.1-7/td ?:Xn pursuant to an agreement of the parties at a custody conciliation iffy the provisions of this Order by mutual consent. In the absence of Order shall control. luire - Counsel for Father Iuire - Counsel for Mother BY T14F. MI TR T RICHARD M. BARONE Plaintiff vs. JOANN M. GULA Defendant IN ACCORD. PROCEDURE 1915.3-8, the i 1. The pertinent follows: NAME Ben Joseph Barone IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-6064 CIVIL ACTION LAW IN CUSTODY CE WITH CUMBERLAND COUNTY RULE OF CIVIL ersigned Custody Conciliator submits the following report: concerning the Child who is the subject of this litigation is as OF BIRTH CURRENTLY IN CUSTODY OF 18, 2004 Mother/Father 2. A custody conciliat on conference was held on March 11, 2010, with the following individuals in attendance: the F ther, Richard Barone, with his counsel, John J. Connelly, Jr., Esquire, and the Mother, Joann M. Gula, ith her counsel, Timothy M. Barrouk, Esquire. 3. The parties agreed to Date of an Order in the form as attached. Dawn S. Sunday, Esqui Custody Conciliator JUL 2 0 2010 RICHARD M. BARONE, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 2007-6064 JOANN M. GULA, C1VIL ACTION -LAW Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ day of , 2010, based upon the attached Stipulation for Custody dated July 16, 2010, by and between Richard M. Barone, Plaintiff/Father and Joann M. Gula, Defendant/Mother said Custody Stipulation is hereby made an Order of this Court. By the Court: Di~'bution: ./John J. Connelly, Jr., Esquire PO Box 650, Hershey, PA 17033 ~mothy M. Barrouk, Esquire, 4807 Jonestown Road, Suite 148, Harrisburg, PA 17109 ?~/~~..,a,l~L ~ ~ . _; c~~ C --- ~ ; ~ -~}_t -~ i ~ r ~. a. ~..... -; r r~; Q f~i - _= ~_~ I-~ r.r -~ SEP 0 7 2010 RICHARD M. BARONE IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. 2007-6064 CIVIL ACTION L o '~i cn r*a ~ JOANN M. GULA ~ ~ ~' ~ ~ ~ r. Defendant IN CUSTODY ~~cl *,,, ~: ~ ~ .~ ~~ ~_ C == ~ - i -~ r ORDER AND NOW, this 1st day of September. 2010 ,the conciliator, having been advised by counsel for the parties that all custody issues have been resolved by agreement between the parties, hereby relinquishes jurisdiction with no need to reschedule the follow-up conference scheduled in the prior Court Order. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator G~~b~p ;: ~ .:, + 1 i :.l ~ r i ~ ~.+ t.. John J. Connelly, Jr., Esquire ~; ~ ~ ~ x ;~, ~;,+ ~ ~ C3 ~^~ ~ ~~~, ~ ,` Attorney I.D. No. 15615 James Smith Dietterick & Connelly, LLP ~~s ~ ;? ~=~vt~ - ~ ~ !~~~,~ P.O. Box 650 Hershey, PA 17033 , t,.'' ^~~~~~}~~ ~d~~~~~ Attorneys for Plaintiff/Petitioner ~, ~ ~ ~~ ~ `(' LV~ ~~ ~ ~ RICHARD M. BARONE, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner :CUMBERLAND COUNTY, PENNSYLVANIA v N0.2007-6064 JOANN M. GULA, :CIVIL ACTION -LAW Defendant/Respondent IN CUSTODY PRAECIPE TO WITHDRAW PLAINTIFF'S PETITION FOR SPECIAL RELIEF TO THE PROTHONOTARY: Please withdraw the Petition for Special Relief filed on October 2, 2012, by Plaintiff/Petitioner, Richard M. Barone, in the above-captioned divorce action. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: ~~~~ By; Attorneys for Plaintiff/Petitioner Richard M. Barone P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 RICHARD M. BARONE, Plaintiff v. JOANN M. GULA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2007-6064 CIVIL ACTION -LAW IN CUSTODY CERTIFICATE OF SERVICE I, John J. Connelly, Jr., Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the Plaintiff/Petitioner, Richard M. Barone, hereby certify that I have served a copy of the foregoing Praecipe on the following on the date and in the manner indicated below: VIA U.S. MAIL, FIRST CLASS. PRE-PAXD Timothy M. Barrouk, Esquire The McShane Firm, LLC 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: L' ~ "' ~~ By: P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff %Ci RICHARD M. BARONE, HO4 o r Plaintiff 2014 ititiG 13 r CUMBERLAND COUNT PENNSYLVANIA JOANN M. GULA, Defendant IN THE COURT OF COMMON PLEAS : ' CUMBERLAND COUNTY, PENNSYLVANIA 6 : NO. 2007-6064 : CIVIL ACTION : IN CUSTODY PRAECIPE FOR WITHDRAW OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Timothy M. Barrouk, Esquire, 4807 Jonestown Road, Suite 148, Harrisburg, PA 17109, as counsel of record on behalf of Defendant, Joann M. Gula, in the above captioned action. DATE: Z Respectfully submitted, TIMOTHY M. BARROUK, ESQUIRE Timothy M. Barrouk, Esquire 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 (717) 657-3900 PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance to represent Defendant, Joann Gula, in the above captioned action. Respectfully submitted, DATE: g �—'1� JOANNE HARRISON CLOU ,PC Joanne ' arrison Cloug quire Attorney ID No.: 3646 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 r CERTIFICATE OF SERVICE I, Connie Lee Limric, secretary to, Joanne Harrison Clough, Esquire ;++ do hereby certify that on this date I served a copy of the foregoing document by United StatesFirst Class Mail to the following individual set forth below: Timothy M. Barrouk, Esquire 4807 Jonestown Road, Suite 148 Harrisburg, PA 17109 John J. Connelly, Jr., Esquire James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Date: R.-/ z- -/ y/ Conroe Lee L.ic, s - 'retary to Joanne Harrison Clough, Esquire Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Joann M.Gula